privacy policy

privacy policy

date of last update: 16/10/2024

Subject and purpose of the Policy – ​​What is the purpose of the Policy? Who does it apply to? Who is the personal data administrator?

This document describes how the owner of the website www.trokentech.pl collects, uses and protects personal data of Users of the website, including the online store.

The owner of the website and the data administrator is TrokenTech sp. z o. o. with its registered office at ul. Bardzka 60, 50-517 Wrocław, entered into the National Court Register - Register of Entrepreneurs under KRS number 0000342475, registration court: District Court for Wrocław - Fabryczna, 6th Commercial Division of the National Court Register; NIP 8992684140; Regon 021122451 (hereinafter "we" or "us").

The information contained in the Privacy Policy applies to website Users, i.e. people visiting our websites, including people who have subscribed to the Newsletter, people applying for employment law advertisements, people contacting us using the forms available on the website and those who make purchases via via the store on the website (customers, consumers).

By visiting the website www.trokentech.pl , subscribing to the Newsletter, applying for a job advertisement, contacting us using the forms available on the website, placing an order in the store, creating an account on the website and concluding a sales contract, you accept and agree to the practices described in this Policy.

Questions, comments and requests regarding this Privacy Policy are welcome and should be directed to the data controller, i.e.:

• to the e-mail address: biuro@trokentech.pl ,
• by phone: +48 71 794 43 44,
• or in writing to the following address: ul. Bardzka 60, 50-517 Wrocław.

Categories of personal data, purposes of processing and legal basis - What personal data do we process and why? What are the legal bases?

1. Data necessary to place an order, create an account, and conclude a sales contract.

The person placing the order fills out the appropriate form on the website, providing data, i.e. name, surname, delivery/registered/shipping address (street, building number, apartment number, postal code, city, voivodeship, country), telephone number and e-mail address. -mail, the buyer who is an entrepreneur also provides the company name and NIP number.

You can place an order both without registration, but also (optionally) by registering/logging in to the store.

By registering on the website, a buyer's account is created. Registration requires the buyer to complete the appropriate electronic form, available on the website, by entering the required data. The scope of data includes the data necessary to place an order, listed above. Registration is voluntary.

Purpose : Providing personal data by the buyer is necessary to place an order and conclude and perform the sales contract. Providing an e-mail address and/or telephone number is necessary to confirm acceptance and execution of the order.

Legal basis:

– art. 6 section 1 letter b) GDPR - processing is necessary to perform the contract to which the data subject is a party, or to take action at the request of the data subject before concluding the contract, i.e. acceptance and execution of the order, conclusion and performance of the sales contract;

– art. 6 section 1 letter c) GDPR - processing is necessary to fulfill the legal obligation of the administrator, among others: resulting from the Accounting Act, i.e. storing accounting documents regarding the implementation of contracts;

– art. 6 section 1 letter f) GDPR - processing is necessary for the purposes of legitimate interests pursued by the administrator or by a third party, i.e. providing customers with information about the execution of the order, ongoing contact with the customer regarding the execution of the order, handling complaints, requests to withdraw from the contract.

2. Data necessary to present an offer containing an investment discount (Wholesale orders form).

If you want to obtain an offer containing an investment discount, the User can send us his telephone number and city name via a dedicated form called Wholesale orders. The form is available on the Website. Sending personal data is voluntary.

Purpose : Data will be processed in order to present an offer containing an investment discount.

Legal basis : art. 6 section 1 letter a) GDPR, i.e. the data subject has consented to the processing of his or her personal data. At the same time, we would like to inform you that your consent may be withdrawn at any time, just send such a message to the e-mail address: biuro@trokentech.pl . Such withdrawal of consent will not affect the legality of processing prior to withdrawal.

3. Data for the Newsletter.

If you wish to receive the Newsletter from us, we collect and process the User's data, i.e. name and e-mail address.

Purpose : Data related to the Newsletter will be used to provide marketing information to promote products, blog, YouTube channel and Facebook fanpage.

Legal basis : art. 6 section 1 letter a) GDPR, i.e. the data subject has consented to the processing of his or her personal data for one or more specific purposes. At the same time, we would like to inform you that your consent can be withdrawn at any time, just send such a message to the e-mail address: biuro@trokentech.pl or click on the deactivation link that is in each of our Newsletter. Such withdrawal of consent will not affect the legality of processing prior to withdrawal.

You can read more about the Newsletter service in the Newsletter Regulations.

4. Data of job candidates.

If you send us a recruitment application, the candidate agrees to the processing of his or her personal data in the provided recruitment documentation, including: in your CV.

Purpose : We will process the candidate's data for the purpose of recruitment, and if consent is given, also during future recruitment.

Legal basis:

– art. 6 section 1 letter c) GDPR - processing is necessary to fulfill the legal obligation of the administrator, i.e. resulting from the Labor Code - in terms of name(s), surname, date of birth, contact details provided by the candidate, education, professional qualifications and previous employment history,

– art. 6 section 1 letter b) GDPR - taking action at the request of the data subject before concluding a contract or taking action at the request of the data subject before concluding a contract,

– art. 6 section 1 letter a) GDPR - consent of the data subject - if the application documents contain personal data beyond the scope specified in the Labor Code,

– art. 6 section 1 letter a) GDPR - consent of the job candidate to the processing of data during future recruitment,

– art. 6 section 1 letter a) GDPR - consent of the job candidate to the processing of his additional personal data not specified in the law (e.g. image, interests),

– art. 6 section 1 letter f) GDPR - processing is necessary for the purposes of legitimate interests pursued by the administrator or a third party, i.e. determining, investigating or defending against claims.

5. Data regarding the use of the Website.

In connection with your visit to the website, we collect the following information: browser data (e.g. type, version, language); operating system and interface data; details of the website from which you were redirected (referrer URL); data of websites visited on our website; the date and time you accessed our website; access status/HTTP status code, amount of data transferred, Internet Protocol (IP) address. This data is collected in the form of cookies - you can read more about it in the banner about cookies that appears during your first visit to the website, the same banner also appears after clicking the widget ("safety pin" in the lower left corner of the page) file settings cookie -> change your consent.

Purposes : Usage Data will be used to provide access to the website, facilitate the use of the website and to detect technical errors and/or errors in the transmission of electronic communications. The data will also be used for statistical purposes, i.e. collecting information on the use of our website by Users.

Legal basis:

– art. 6 section 1 letter f) GDPR - processing is necessary for the purposes of legitimate interests pursued by the administrator or a third party. These interests are intended to provide the User with access to the website as requested and to achieve the other purposes set out above. The legal basis concerns the use of essential cookies.

-art. 6 section 1 letter a) GDPR - the data subject has consented. The legal basis concerns the use of external statistical cookies. During the first visit to the website, information about the use of cookies is displayed to the User. Here, the user can choose which types of cookies he consents to. While using the Website - at any time - the User can also modify his/her consent by clicking on the cookie widget appearing on each page (in its lower left corner) and then changing the settings in the banner that appears.

Retention periods – How long do we store personal data?

The customer's personal data will be stored for settlement purposes for a maximum period of 5 years, counting from the end of the calendar year in which the tax payment deadline related to the contract concluded in the store expired. To the extent justified by the purposes of processing, personal data will be stored as long as there is a legal basis for their processing, unless applicable legal provisions would require a longer period of storage. At the end of the storage period, personal data will be deleted or anonymized.
If we process the User's personal data on the basis of additional consents - provided that they express them, of course - we process them until the previously granted consent is withdrawn. In the case of processing personal data for direct marketing purposes - we process them until you object to their processing.
To summarize, we store Users' data no longer than necessary to achieve the purposes for which they were collected, unless applicable law requires us to store them longer.

Categories of recipients and international transfers – Who do we send personal data to and where is it located?

We provide the collected personal data of the customer to the selected carrier or intermediary carrying out shipments on our behalf. In the case of a customer who uses electronic payment or a payment card, we share the customer's collected personal data with the selected entity handling the above payments. We may also transfer data to suppliers to whom we commission services related to the processing of personal data, e.g. IT service providers, entities operating the website. Such entities process data on the basis of the entrustment agreement concluded with them and only in accordance with our instructions.

Each case of granting access to Users' personal data is limited to those persons/entities who need to gain access to Users' data in order to fulfill their professional obligations. We will also share Users' personal information as required or permitted by applicable law with professional advisors, government authorities and courts.

The Google tools we use allow the User's personal data to be processed on a server in the United States. In these cases, Google may process the User's personal data outside the European Economic Area, but this is done on the basis of an adequacy decision, the so-called Data Privacy Framework or based on the so-called standard contractual clauses, provisions of the contract concluded between us and Google, which guarantee an adequate level of secure processing of the User's personal data.

Cookies – how do we use them?

Like many other websites, we also use so-called "cookies". Cookies are small text files that are transferred from a website's server to your hard drive. This automatically gives us certain data such as IP Address, browser used, operating system and Internet connection.
Based on the information contained in cookies, we can facilitate navigation and enable our website to be displayed correctly. These files are in no way harmful to your device and do not change its settings or the settings of the software installed on it.
The law states that cookies can be stored on the User's device if it is necessary for the functioning of the website. For all other types of cookies, the Administrator requires the User's consent.

Necessary cookies are processed by the Administrator on the basis of the legitimate interests of the Administrator and Users. Other cookies are processed based on the user's consent.

When entering the website www.trokentech.pl , the User will see information about cookies (banner at the bottom of the page). The user is informed here what cookies we use on the Website and can choose what types of cookies he or she consents to.

Moreover, the User may withdraw his/her consent or change his/her preferences at any time by clicking on the cookie widget appearing on each page (in its lower left corner) and then changing the settings in the banner that appears.
Moreover, by default, the software used for browsing websites (browser) allows the use of cookies on the user's device on which it is running. In most cases, you can configure the software yourself, including forcing automatic blocking of cookies. Issues related to the configuration of cookie handling can be found in the software settings (web browsers). Please note that some features of our website may not work if you have disabled the use of cookies. Detailed information about the possibilities and methods of handling cookies is available in the software settings (web browser: Opera, Firefox, Internet Explorer, Chrome, Safari). In no case will the data we collect be transferred to third parties without the user's consent.
Full and constantly updated information about the cookies used on the website can be found in the banner that appears during your first visit to the website, the same banner also appears after clicking the widget ("safety pin" in the lower left corner of the page) cookie settings -> change your consent.

Analytical and marketing tools – which ones do we use?

1. Thulium

The website uses software that ensures efficient management of contact with the User and other persons interested in our activities for the User's convenience and to ensure the highest quality of customer service, i.e. a tool provided by Thulium. As part of the plug-in implemented on our website, the User can initiate contact with us in real time and leave his/her data with an indication that he/she requests contact at a later date (in this case, you indicate the telephone number and IP address, which approximately determines the User's location. The User has the possibility of leaving your message, which is registered in the system as a notification (in this case, you indicate your name, e-mail address and message content in the form). The supplier of the tool is Thulium sp. z o. o.
The legal basis for using the Thulium tool is Article 6 section 1 point a) of the GDPR, i.e. consent of the data subject for the purpose of marketing products and services of TrokenTech sp. z o. o. and contact by telephone and/or contact by email/text message/mms. At the same time, we would like to inform you that your consent may be withdrawn at any time, just send such a message to the e-mail address: biuro@trokentech.pl. Such withdrawal of consent will not affect the legality of processing prior to withdrawal.

2. Trusted Shops

If the User has agreed to provide a review of the purchase during or after placing the order (Article 6(1)(a) of the GDPR), then we will use the User's e-mail address to send him an electronic invitation to rate the purchase made in our store. Opinions/ratings are issued via the feedback system we use. The User may withdraw the consent granted at any time by sending a message informing about the withdrawal of consent to our e-mail address: biuro@trokentech.pl . Alternatively, the User may also use the link unsubscribing from the list of newsletter recipients included in the message with the invitation to leave an opinion.

Invitations to leave a review are sent by our service provider Trusted Shops GmbH Subbelrather Str. 15C, 50823 Cologne, Germany (Trusted Shops). As part of sending invitations, we receive status information from Trusted Shops (e.g. whether a given invitation to leave a review has been sent and whether it has reached the recipient). This is done in accordance with Art. 6 section 1 letter f GDPR in order to pursue our legitimate interest in receiving information regarding invitations to submit opinions in order to be able to make optimizations on this basis, if necessary.

3. Google Ads

This is an advertising tool of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, which allows us to create valuable advertisements for Users. Detailed information on how Google uses cookies to display ads and how to manage your settings is available at: https://policies.google.com/technologies/ads?hl=pl .
Details related to data processing within Google Analytics can be found at the following link https://support.google.com/analytics/answer/6004245?hl=pl .

4. Google Analytics

This is a set of tools from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, which enable us to collect statistical information regarding your use of the website, such as IP address, device type, browser type. We do this to have knowledge, among others: about the number of users using our website. This information is only processed in a way that does not allow us to directly identify anyone. Detailed information on protection and terms of use can be found at the following link: https://marketingplatform.google.com/about/analytics/terms/pl/ .

5. Microsoft Clarity

It is an analytical tool that collects information about the behavior of Users and their end devices, in particular the IP address of the device (recorded and stored in an anonymized form), screen resolution, type of device, information about the browser the user uses, geolocation (country). Clarity stores this information in a pseudonymized User profile, the storage period is 1 year. This tool allows you to analyze user behavior on the Website in order to improve its functionality. More information can be found in the Microsoft Privacy Policy: https://privacy.microsoft.com/pl-pl/privacystatement .

6. Google Tag Manager

Google Tag Manager is a tool for managing tags and scripts on websites and profiles on social media platforms. It allows Google to collect data such as information about how tags and services are used, as well as about the tags themselves that are used.
All data is processed in accordance with Google's privacy policy, which is available at: https://policies.google.com/privacy .

7. LinkedIn Insight Tag

The website uses LinkedIn Insight Tag, an analytical tool offered by LinkedIn Corporation. Insight Tag is JavaScript code that tracks conversions and analyzes traffic on our website using cookies. Collects visit data such as URL, IP, device type, browser, and timestamp. IP addresses are shortened or encrypted and LinkedIn user IDs are deleted within seven days, rendering the data pseudonymous. This data is stored for a maximum of 90 days.

LinkedIn does not provide the website operator with direct personal data, but provides anonymous reports on advertising performance and allows retargeting of visitors to our website.

More information about LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy .

8. Facebook pixel

The website uses "Website Custom Audiences" pixels provided by Facebook. This means that these pixels are integrated with the website, enabling the display of targeted ads, optimizing their effectiveness and measuring the reach of marketing activities. During a visit to the website, the Facebook pixel connects the user's browser to the Facebook server by saving a cookie, which allows the visit to be tracked based on the IP address. If you have a Facebook account, this information may be linked to your profile and used to display personalized ads, unless you have objected to such activities in your account settings.
As the website operator, we have no access to the detailed data transferred to Facebook or their precise use. Details on this subject are available in Facebook's Privacy Policy: https://www.facebook.com/about/privacy .

9. YouTube video use

Video recordings from YouTube are posted on the website. Playing these recordings involves the use of cookies by Google (Google Ireland Limited), which provides the YouTube service. Further information provided by Google on data protection on YouTube can be found by clicking on the following link: https://policies.google.com/privacy?hl=en&gl=en .

10. MailerLite

MailerLite is a newsletter management tool that collects information about user behavior in order to optimize mailing campaigns. In particular, it collects data such as e-mail address, information about opening messages, clicking on links, as well as the user's IP address (stored in an anonymous form), device type and browser used. The tool also allows tracking the user's location (country), which allows for the analysis and personalization of content. This data is stored in pseudonymized user profiles for up to 1 year. MailerLite is used to monitor campaign effectiveness and tailor content to your audience.

More information can be found in MailerLite's Privacy Policy: https://www.mailerlite.com/pl/legal/privacy-policy .

Data security – how do we protect personal data?

All Users' personal data obtained via our website are processed in a way that ensures their security, in accordance with the provisions of generally applicable law, in particular the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of persons natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

User rights – what rights do Users have and how can they exercise their rights?

The Website User has the right to:

• access to data and receiving a copy thereof. You have the right to obtain confirmation from us as to whether we process your personal data, and if so, you have the right to:
  • gain access to your personal data,
  • obtain information about the purposes of processing, categories of personal data processed, about the recipients or categories of recipients of this data, the planned data storage period or the criteria for determining this period, about the User's rights under the GDPR and the right to lodge a complaint with the supervisory authority, about the source of this data , on automated decision-making, including profiling and on the safeguards used in connection with the transfer of this data outside the European Union,
  • obtain a copy of your personal data.
• to rectify (correct) data . The user has the right to rectify and supplement the personal data provided by him/her. You have the right to request us to rectify this data (if it is incorrect) and complete it (if it is incomplete);

• to delete data (right to be forgotten) – if in the User's opinion there is no basis for us to process his data, he may request that we delete it. The user has the right to request the deletion of personal data if:
  • withdrew specific consent, to the extent that personal data were processed based on the User's consent,
  • the User's personal data are no longer necessary for the purposes for which they were collected or processed,
  • objected to the use of data for marketing purposes,
  • objected to the use of data for the purpose of keeping statistics on the use of the website, and the objection was found to be justified,
  • personal data are processed unlawfully.

Despite the request to delete personal data, in connection with raising an objection or withdrawing consent, we may retain certain personal data to the extent necessary for the purposes of establishing, pursuing or defending claims. This applies in particular to personal data including: name, surname, e-mail address and application history, which we retain for the purposes of considering complaints and claims related to the use of our services;

• restrictions on data processing – The User may request that we limit the processing of his personal data only to storing them or performing activities agreed with the User, if in his opinion we have incorrect data about him or we process them unjustifiably, or the User does not want us to delete them because he needs them to establish , pursuing or defending claims, or for the period of objection to data processing. The User has the right to request restriction of the use of his or her personal data in the following cases:
  • when you question the accuracy of your personal data - then we will limit their use for the time needed to verify the accuracy of your data,
  • when the processing of the User's data is unlawful and instead of deleting the data, you request restriction of their use,
  • when the User's personal data are no longer necessary for the purposes for which we collected or used them, but they are needed by the User to establish, pursue or defend claims,
  • when the User has objected to the use of his or her data - then the limitation is for the time needed to consider whether - due to the User's particular situation - the protection of his or her interests, rights and freedoms outweighs the interests that we pursue by processing the User's personal data;
• object to the processing of User's data for the purposes of direct marketing. If the User exercises this right, we will stop processing data for this purpose. If the User's objection turns out to be justified and we have no other legal basis for processing the User's personal data, we will delete the User's data to the use of which he objected;
• submit a complaint to the supervisory authority . You may submit to us complaints, inquiries and requests regarding the processing of your personal data and the exercise of your rights. If the User believes that we are processing his or her data unlawfully, he or she may submit a complaint to the supervisory authority based at ul. Stawki 2 in Warsaw;
• withdraw consent to the processing of your personal data . Withdrawal of consent takes effect from the moment of withdrawal. Withdrawal of consent does not affect the processing carried out by us lawfully before its withdrawal. Withdrawal of consent does not result in any negative consequences for the User. However, it may prevent you from continuing to use services or functionalities that we can legally only provide with your consent.

To exercise your rights, please contact us by e-mail at: biuro@trokentech.pl .
In the event of a notification, TrokenTech sp. z o. o. will make every effort to recognize the request as quickly as possible. However, the request cannot always be fulfilled. For example, the right to delete data cannot be exercised if the obligation to store data is based on a legal provision. The User will be informed in writing or by e-mail about the recognition of the request.

Changes to this Privacy Policy

In order to ensure that our Policy meets current statutory requirements at all times, we reserve the right to make changes to it at any time. We recommend that you check this page frequently and refer to the last updated date above.